NC0003760_Corrective Action Plan_20190401

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4 OUpoNT DuPont Kinston Plant
' 4693 Hwy. 11 North
Grifton,NC 28530
April 1,2019
CERTIFIED MAIL: 7016 2710 0000 0959 4986
RETURN RECEIPT REQUESTED �NRI�WR2019 NC Division of Water Resources Ar
NPDES Complex Permitting Unit RECE%JE�U d 1 -
1617 Mail Service Center Water Resources
Raleigh,NC 27699-1617 p®rm►t'.k►9 Section
Re: Permit No.NC0003760: A. (13) Schedule of Compliance Total Copper, Total Lead, Total Silver,
and Total Zinc Outfalls 002& 003 Year 2 Summary Report& CAP.
The following compliance aspects were addressed during the second year of the 5-year compliance
schedule.
a) Document any identified sources of the Total Copper, Total Lead, Total Silver, and Total Zinc:
Since the plant is not manufacturing any chemicals or using any raw materials with heavy
metals,the site's investigation focused on the infrastructure of the site. The site started
manufacturing polyester fibers,polyethylene terephthalate(PET) in 1953 and 66 years later,the
site continues to manufacture poly trimethylene terephthalate (PTT) a polyester polymer.
The site's large infrastructure is constructed of materials that contain zinc, lead, and copper and
many of these buildings have deteriorated. A major effort and significant investment for
demolition and removal (D&R)of obsolete equipment,piping, tanks and buildings was
initiated 2 years ago and continues through 2019.
In addition to the D&R work at the site,most of the remaining galvanized steel buildings have
been painted to inhibit additional corrosion.
b) Submit a report summarizing the identified pollutant sources and source reduction alternatives
that were investigated: The site's age and infrastructure is contributing to the sources of zinc,
copper and lead. Outfall 002 receives waters from the heart of the manufacturing area, where
two main stormwater trunks direct water down from buildings (roofing, siding, downspouts)
piping, and tanks through the outfall. The catch basins contributing to outfall 002,will be
cleaned out(CAP task)to remove accumulated material.
A walk-through audit of outfall 002 identified 4-galvinized steel culverts that are corroded
through at the bottom and being washed out from erosion. A capital project was funded to have
all 4 culverts removed from the outfall; eliminating this potential source of zinc. This project
will be completed by mid-year 2019.
A grassed swale was constructed for outfall 004 several years ago to address zinc containing
runoff from the aging warehouses near that outfall. After the grassed swale was installed the
warehouses (over 100,000 square feet)were D&R'd. The site would propose a grassed swale
BMP be installed at outfall 002 as part of the site's CAP (see Figure 1, CAP).
Outfall 003, collects stormwater flows from the front of the site is not impacted by our
manufacturing of PTT. Roofing, siding, downspouts, and other infrastructure materials
contribute to the metals in the stormwater runoff.
DuPont Industrial Biosciences USA,LLC Page 1 of 2

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The catch basins contributing to outfall 003, will be cleaned out(CAP task)to remove
accumulated material.
To collect a more representative sample at outfall 003,the site proposes to move the monitoring
location to a new location further downstream of the current monitoring location(see Figure 2
CAP).
c) Submit a Corrective Action Plan (CAP): See Attached.
As the site closes out year two of the five-year compliance schedule, we will continue study our
stormwater as we work to achieve each milestone in our CAP over the next three years.
If you have any questions,please contact Jon Carpenter, Environmental Manager at 252-522-6255
Sincerely,
orge en is
Plant Mana er
DuPont Kinston Plant
E.I.DuPont de Nemours and Company Page 2 of 2

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DUPONT 4693 Hwy 11 N
NPDES Permit No. NC0003760 Grifton, NC 28530
DuPont Industrial Biosciences USA, LLC April 1, 2019
STORMWATER CORRECTIVE ACTION PLAN (CAP)
This Stormwater Corrective Action Plan (Table 1) has been developed in conjunction with A. (13)
Schedule of Compliance Total Copper, Total Lead, Total Silver, and Total Zinc for Outfalls 002&003 to
address compliance with the new lower limits for metals copper, lead,silver, and zinc for the two
(Outfalls 002 &003) combined process/stormwater discharges at DuPont—Kinston Facility, National
Pollutant Discharge Elimination System Permit No. NC0003760.The schedule included in this Plan
provides a means for NCDEQ to assess the progress being made on each milestone.
Table 1: Overall Schedule
TASK MILESTONES COMPLETION DATES NCDEQ ACTION
Phase 1 (Year 1&2)
Review new permit May 2017 Issued NPDES permit
limits and effective on April 1,
requirements and 2017
develop the CAP
Review and update, as Audit Tradewaste Lab July 2017
needed,the sampling procedures and sample
techniques used by methods
ORC.
Confirm with outside, Confirmed December 2017
certified lab on their Environment 1,
sample handling Incorporated is
techniques certified to handle all
our stormwater
sampling requirements
Verify Smoking Policy Confirmed site policy is March 2018
for DuPont at the written in the Sorona
Kinston Site Safety Manual,Section
2, Item 200, Rule#2
Select additional Collect samples near May 2017
sampling locations buildings and process
above the actual and compile the
monitoring point for additional data
outfalls 002 &003
Submit summary Summarize year 1 April 1, 2018 Certified Mail signed
report to Div. of Water schedule of compliance return receipt for the
Resources A. (13.) summary letter.
(March 27, 2018)
Sampling events March 2019 April 1, 2018
throughout year 1 and
year 2
Page 1 of 4

OUPONT! 4693 Hwy 11 N
NPDES Permit No. NC0003760 Grifton, NC 28530
TASK MILESTONES COMPLETION DATE NCDEQ ACTION
Summarize findings Provide summary with April 2019
and conditions letter and CAP to Div.
contributing metals to of Water Resources
outfalls 002 &003
Confirm cooling chilled, ChemTreat SDS: No January 2019
and Boiler water metals listed in any of
treatment chemicals the treatment
don't contain metals chemicals
Research possible Based on data,select March 2019
BMPs BMP(s)to improve
water quality
Meet with Kinston site Staff meeting March March 26, 2019
Leadership to present 26, 2019 led by Plant
data and Manager
recommendations for
improvements
Submit summary Certified mail cover April 1, 2019
report (with CAP)to letter and CAP
Div. of Water according to A. (13.)
Resources Year 2
Phase 2(Year 3&4)
Pending approval of Receive CAP approval
Corrective Action Plan from Div. of Water
(CAP)from NCDEQ, Div. Resources
of Water Resources
Clean out any Complete basin
sentiment found in the cleanout project by End
stormwater catch of Summer 2019
basins along the flow of
outfalls 002&003
Consult with Supplier Seek supplier data on
and test for impact of impact of water
water treatment treatment chemicals
chemicals on the and sample treated
infrastructure water for metals
Continue sampling Sample during the fall
Outfalls 002 &003 of 2019 above the
above sample location monitoring point for
after cleaning out of each outfall
stormwater catch
basins
Request Engineering to Receive engineered Request Engineering to
design Grassy Swale plan to construct design Grassy Swale
BMP for Outfall 002 Grassy Swale BMP BMP for Outfall 002
(see Figure 1.) (see Figure 1.)
Page 2 of 4

0UPON1! 4693 Hwy 11 N
NPDES Permit No. NC0003760 Grifton, NC 28530
TASK MILESTONES COMPLETION DATE NCDEQ ACTION
Develop SOC for new SOC Complete
monitoring point for
Outfall 002 (see Figure 2.)
Develop Scope of Work Scope of Work
to establish new complete
monitoring point for
Outfall 003
Seek Funding to move Funding approved for
monitoring point to new monitoring point
new location at Outfall for Outfall 003
003
Select Contractor& PO issued to contactor
Request Purchase to construct new
Order(PO)to construct monitoring location for
the new monitoring Outfall 003
point on Outfall 003
Submit summary Summarize year 3 Due by April 1 2020
report to Div. of Water schedule of compliance
Resources A. (13.)
Construct Grassy Swale Complete Construction
BMP at Outfall 002 Project
Install new Monitoring Complete Installation
Point at Outfall 003 Project
Submit summary Summarize year 4 Due by April 1,2021
report to Div. of Water schedule of compliance
Resources A. (13.)
Phase 3(Year 5)
Prepare separate Submittal of NPDES Due no later than
NPDES Permit Permit application September 30,2021
application (180 days prior to
expiring)
Prepare separate Submittal of Due no later than
Stormwater Permit Stormwater Permit September 30, 2021
application application (180 days prior to
expiring)
NPDES Permit review Receive approval of TBD (Permit expires at Pending issuance of
and approval by NC new NPDES Permit midnight March 31, new NPDES Permit
Div. of Water 2022)
Resources-NPDES
Stormwater Permit Receive approval of TBD(Permit expires at Pending issuance of
review and approval by new Stormwater midnight March 31, new Stormwater
DEMLR Stormwater Permit 2022) permit
Page 3 of 4
1

4OUPONT! 4693 Hwy 11N
NPDES Permit No. NC0003760 Grifton, NC 28530
Submit summary Summarize year 5 Due by April 1, 2022
report to Div.of Water schedule of compliance
Resources A.(13.)
Figure 1: Proposed BMP: Grassed Swale
Cooling Tower
\e Dismantled
Goa and Removed
ayyed \\p0� (2018)
G ,
c Ea
J
00e O
ed
0613
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Figure 2: Proposed site for new sampling location.
Proposed New Sampling
P P 9
Location
Outfall 003 Sampling
Location Google
Page 4 of 4